Docket 24-1287
Learning Resources Inc. v. Trump
DecidedFeb 20, 2026
6-3decision
Source: CourtListener.
Supreme Court rules President cannot use emergency powers law to impose tariffs
What it does
The Court holds that IEEPA does not authorize the President to impose tariffs, striking down the drug-trafficking tariffs on Canada, Mexico, and China and the "reciprocal" tariffs imposed on nearly all countries. It vacates the district court's judgment in the Learning Resources case for lack of jurisdiction (ruling that such tariff challenges must go to the Court of International Trade) and affirms the Federal Circuit's judgment against the tariffs in the V.O.S. Selections case.
Who benefits
Small businesses and importers who paid the challenged tariffs and may now be eligible for refunds, and states that challenged the tariffs as unlawful.
Who is affected
The President's ability to unilaterally set tariff rates on imported goods from any country under emergency authority is curtailed; the executive branch must now rely on other, more procedurally constrained tariff statutes (such as Section 232 or Section 301) to impose similar duties.
Practical impact
The federal government may need to refund billions of dollars in tariffs already collected from importers, a process acknowledged at oral argument to likely be complicated. Trade agreements the administration negotiated using the leverage of these tariffs may face renewed uncertainty, though the dissent notes the President could likely reimpose similar tariffs under other statutes like Section 232 or Section 301, subject to additional procedural requirements.
Majority reasoning
The Chief Justice's opinion, writing for the Court on the core holding, explained that Article I gives Congress alone the power to tax, including tariffs, and the government conceded the President has no inherent peacetime tariff power. Reading IEEPA's authorization to "regulate... importation" as allowing unlimited tariffs would be an extraordinary and unprecedented delegation of Congress's taxing power, and courts require clear congressional authorization before finding such sweeping delegations in ambiguous text. The word "regulate" as used throughout the U.S. Code never has been found to include the power to tax, and the neighboring verbs in the statute (investigate, block, direct, compel, nullify, void, prevent, prohibit) all describe control actions, not revenue-raising. The majority rejected the government's reliance on the Yoshida case involving President Nixon's 1971 tariffs under IEEPA's predecessor, TWEA, finding a single limited appellate decision insufficient to establish settled meaning that Congress incorporated into IEEPA, and distinguished Algonquin and Dames & Moore as involving different statutory language and issues.
Dissent reasoning
Justice Thomas, dissenting, joined Justice Kavanaugh's opinion in full and separately argued that the nondelegation doctrine, rooted in the Vesting and Due Process Clauses, only bars Congress from delegating power to set rules depriving people of life, liberty, or property; because importing goods is a privilege rather than a right, Congress may freely delegate the tariff power to the President without any separation-of-powers problem. Justice Kavanaugh, joined by Thomas and Alito, argued that the phrase "regulate... importation" has long been understood, through dictionary definitions, historical practice, and the Algonquin precedent, to include tariffs, and that Congress clearly authorized tariffs when it reenacted this language in 1977 knowing it had just been used to justify President Nixon's tariffs. He further argued that even if the majority's major-questions doctrine applied, the historical record supplies the required "clear congressional authorization," and alternatively that the doctrine should not apply at all in the foreign-affairs context, where courts have traditionally read statutes as written and given the President broad discretion.
Constitutional question
Does the International Emergency Economic Powers Act (IEEPA), which lets the President "regulate... importation" during declared national emergencies, give the President power to impose tariffs (taxes on imported goods)?